68% cite cross-platform data access as their top challenge
Over 50% are testing or adopting Data Clean Rooms and Unified IDs
26th November, Brussels, Belgium - IAB Europe, the leading European-level industry association for the digital advertising industry, has today released the first Pan-European Report on the Adoption of Addressability & Measurement Solutions, revealing how advertisers, agencies, publishers, and technology providers across Europe are navigating the shift toward a privacy-first digital ecosystem.
The report reveals that although nearly 9 in 10 respondents are at least somewhat familiar with addressability, true expertise remains concentrated in ad tech companies and agencies, with advertisers displaying notable knowledge gaps.
Key Findings From the Report
Commenting on the report’s findings, IAB Europe’s Digital Advertising Product Manager, Lucio Gagliardi, said, “The findings show real progress, but they also highlight that many organisations, particularly brands, still need deeper support to assess and implement addressability and measurement solutions with confidence. Ensuring the industry moves forward together will require strong education, clearer guidance, and alignment on standards.”
Wayne Tassie, Group Director, NL at DoubleVerify & Chair of IAB Europe’s Advertising & Media Committee, also commented, “As Europe accelerates toward a privacy-first advertising ecosystem, Addressability and Measurement sit at the core of this transformation. This research shows momentum across the industry and highlights the uneven adoption and fragmentation that continue to slow progress.
Organisations require clarity to map their vision. Regardless of whether you are an advertiser, agency, publisher, or technology provider, there is a common need for consistent guidance, interoperable solutions, and stronger alignment across markets. The goal of the Advertising and Media Committee is to help bridge these gaps by supporting industry education, fostering collaboration, and championing practical standards that allow every part of the ecosystem to move forward with confidence.”
As part of our ongoing mission to support a privacy-first digital ecosystem, we will continue to develop educational and best-practice resources, helping all stakeholders to understand and build the expertise needed to navigate identity, data, and measurement in Europe.
About the Study
Developed by IAB Europe’s Addressability & Measurement Working Group, the survey gathered responses from more than 79 advertisers, agencies, publishers, and technology providers across 27+ European markets.
The full report is now available on our website here.
Our Sustainability Standards Committee is excited to share that the fourth annual State of Readiness Survey is open for your input.
Whether you’re on the buy or sell side, working locally or regionally, we invite you to share your voice to help build a clear picture of how our industry is moving toward sustainable practices.
As sustainability expectations continue to increase from consumers, regulators, and partners alike, our industry has a critical role to play. This survey helps us understand where we stand today, including the attitudes, actions, and challenges companies are facing as they work to reduce their carbon footprint and embed more sustainable practices across the digital advertising value chain.
What’s New This Year
For the first time, the survey includes an expanded focus on social impact. This addition acknowledges that sustainability today is not only about environmental progress but also about people, responsibility, and societal outcomes.
Why Your Participation Matters
Your insights are essential in fueling the future of our industry and what we do next when it comes to sustainability. The survey findings help us:
Every piece of information you share helps strengthen our understanding and build a more sustainable overview for digital advertising.
🗓️Deadline to participate: 30th January, 2026
We’ve also collaborated with several of our National Federation partners to make this survey available in multiple local languages. You can complete the survey in your local language in the following markets. Simply select your preferred language from the options in the top right corner of the survey :
Thank you for contributing to this important initiative!
Brussels, Belgium, 17th November 2025: IAB Europe - together with ACEA (European Automobile Manufacturers’ Association), Connect Europe, EACA (European Association of Communications Agencies), EACB (European Association of Co-operative Banks), EAIF (The European AI Forum), EBF (European Banking Federation), egta (the international trade body of multiplatform TV and audio businesses), EPC (European Publishers’ Council), EUTA (European Tech Alliance), EU Travel Tech, FEDMA (Federation of European Data and Marketing), GSMA, IATA (International Air Transport Association), Insurance Europe, and Video Games Europe - has sent a joint letter to EDPB Chair Anu Talus regarding the Board’s initiative to organise a stakeholder event on anonymisation and pseudonymisation following the CJEU ruling in Case C-413/23 EDPS v. SRB.
The letter notes that the CJEU’s clarification that pseudonymised data may, in certain circumstances, effectively qualify as anonymous creates an important opportunity to advance the objectives of the EU Data Strategy and strengthen Europe’s capacity to develop and deploy innovative technologies across all sectors of the economy.
The signatories call on the EDPB to ensure a participatory event format, including active involvement of EDPB members, balanced representation from public and private stakeholders, and the presentation of concrete use cases to demonstrate how anonymisation and pseudonymisation work in practice.
The letter further highlights the importance of developing practical and operational frameworks for anonymisation and pseudonymisation for companies to innovate with legal certainty, including tools such as checklists and interpretative grids, as well as exploring the role of certification schemes.
The undersigned associations look forward to contributing their expertise to the upcoming stakeholder workshop and support the EDPB’s ongoing work in this area.
The letter can be found here. For more information, please contact IAB Europe’s Privacy Director, Ninon Vagner at vagner [at] iabeurope.eu.
Programmatic advertising is constantly changing with new technologies emerging, and rising expectations around transparency and efficiency. On 26th November at 12:00 CET, we’re bringing together leading experts from across the digital ecosystem for our H2 2025 Virtual Programmatic Day (VPD).
Hosted by Nick Welch, Senior Director, Programmatic & Sell-side Development, IAS, this virtual event will explore the biggest trends and challenges that will define the next phase of programmatic growth.
This latest edition of VPD will offer fresh insights, practical guidance, and future-focused discussion on topics such as:
We’re excited to announce that the following speakers will be joining us on the virtual stage:
Alice Beecroft, Snr. Dir. Global Strategy & Partnerships, Yahoo
Bal Singh, Associate Group Director, Regional Client Partnerships - EMEA, DoubleVerify
Clara De Rosa, Head of Customer Success UK, Adform
Gabrielle Le Toux, Sr Director Product Marketing, FreeWheel
Sotiris Oikonomou, Managing Director, MarkApp
Mark Evans, Head of Buyer Development UK, Index Exchange
The full list of speakers can be found here, and keep your eyes peeled for more being added very soon.
Register below to secure your free virtual place at Europe’s largest virtual programmatic event.
Our Public Policy Manager, Inés Talavera de la Esperanza, shares her thoughts on the Commission's newly published Consumer Agenda for 2025-2030.
Today, the European Commission published its long-awaited Consumer Agenda for 2025–2030 - and with it, confirmed the preparation of the Digital Fairness Act (DFA) . This proposed new regulation, coming at a time when Commission President Ursula von der Leyen has prioritised and EU leaders have demanded simplification and regulatory restraint to foster competitiveness and growth in the European Union. This raises a crucial question: How will this push for new consumer protection rules align with the promise to simplify the EU’s regulatory landscape?
The EU’s prosperity depends on ensuring that rules are proportionate, targeted and do not overburden businesses, especially small and medium enterprises. This is particularly true for the digital advertising sector, which Executive Vice-President Ribera called "the backbone of the online economy".
And yet, at the same time, the Commission is preparing a Digital Fairness Act (DFA) that seems poised to introduce new layers of regulation to an already crowded, complex and recent rulebook.
The Commission is trying to reassure digital businesses by promoting the Digital Fairness Act (DFA) under the banner of “filling gaps” and “simplifying rules for businesses in the EU.” Yet few in the digital economy would describe additional rules coming as part of a DFA as “simplification”
The paradox is striking. Europe’s digital advertising ecosystem is already heavily regulated by data protection, consumer, and digital laws.
Take, for instance, the issue of so-called “dark patterns” and “click fatigue.” The Commission raised this topic in its recent public consultation on the potential Digital Fairness Act. Specifically, when talking about cookie banners, it’s a legitimate user experience issue — but not a consumer protection problem. It’s a question of data protection compliance under the GDPR and ePrivacy rules.
National Data Protection Authorities have already issued divergent guidance on this, leading to a patchwork of interpretations across Member States. Adding a new consumer-law layer would only deepen that fragmentation.
If simplification is truly the goal, the answer lies not in new rules but in better coordination among existing ones. This should be addressed during existing simplification workstreams, such as the Omnibus packages.
Another emerging idea in the DFA consultation is to regulate targeted advertising based on a consumer’s “vulnerability” - for instance, “negative mental states.” In practice, it raises serious technical and legal challenges. Detecting such states in real time is in tension with data protection rules as it would require collecting and processing sensitive personal data - information about an individual’s financial situation or health - that are endowed with special protection under the GDPR.
If individuals don’t give explicit consent to process this type of data, companies cannot lawfully identify if they have vulnerabilities. The result? An idea that is impossible to comply with, resulting in a de facto ban on personalised advertising.
Another area where a DFA would reinvent the wheel is influencer marketing. The Commission has included the possibility of tackling harmful practices under the initiative. However, a wealth of EU and national-level industry-led initiatives, such as AdEthics, which has been endorsed by Justice Commissioner McGrath, are working effectively to promote responsible behaviour online across the EU. Again, the real challenge is not a lack of regulation, but ensuring consistent enforcement and awareness of what already exists - and supporting the effective industry-led initiatives.
DG JUST’s consumer strategy, and the future Digital Fairness Act risk departing from the simplification principle guiding the second von der Leyen Commission. With the EU27 asking the Commission to demonstrate regulatory self-restraint, the DFA” will serve as an early indicator of whether that commitment is genuine. Simplification must mean simplification, i.e. fewer, clearer, and coherent rules.
For more information on our policy work and how you can get involved, visit our Policy Hub.
It’s been a little while since we gathered in Amsterdam for our Retail Media Impact Summit. But the conversations are still buzzing. From debates to follow-ups and committee discussions, the themes that surfaced are continuing to shape how we think, plan, and collaborate in retail and commerce media today.
So, we thought… why not keep the momentum going?
To round up the week, we’re revisiting some of the standout ideas from the Summit and also highlighting the latest releases from our Retail Media Roundtable podcast series, recorded live at the event.
Whether you’re in 2026 planning mode, building your Retail Media roadmap, or just curious about where all this is heading, check out some of the ideas and content below.
In this roundtable session, attendees discussed the realities of moving from silos to synergy. Teams are calling for a truly omnichannel mindset, tracking performance across every touchpoint: on-site, in-store screens, CTV, DOOH, and beyond.
Installation isn’t the finish line; it’s the starting point.
Post-install efforts must focus on proving ROI, refining audience fit, and building go-to-market clarity through real case studies. You can read more on Zitcha’s website here.
One retailer. One shopper. One strategy.
This message resonated deeply, highlighting the need for integrated planning and better internal collaboration to unlock Retail Media’s full potential.
Another theme we’re still unpacking is incrementality.
A live poll during the Summit found that around 60% of attendees see incrementality as a worthy goal, but not easy to execute today. The conversation that followed was rich.
To support the market on this journey, we’ve partnered with IAB US to release new Guidelines for Incrementality Measurement in Commerce Media, outlining four potential approaches:
While experiment-based methodologies remain the gold standard, model-based and hybrid methods are gaining favour as more scalable and pragmatic options.
The takeaway? Incrementality is absolutely achievable, but only through collaboration, shared frameworks, and improved data accessibility.
You can explore the full write-up here.
We’re also sharing a fresh round of our Retail Media Roundtable podcast episodes that build on some of these conversations and more, offering a mix of perspectives on strategy, activation, measurement, and what’s next.
Listen to all our podcasts here.
We’ll continue spotlighting learnings, examples, and discussions in the weeks ahead, so keep an eye out. And in the meantime, why not head over to our Retail Media Hub for more information, insights and an overview of our work.
With COP30 taking place next week in Brazil, global attention is once again turning to the urgent need for collective climate action. While headlines often focus on heavy-emitting industries like energy and transport, the environmental impact of the digital ecosystem (and the advertising supply chain within it) is also impossible to ignore.
Every ad impression, data transfer, and supply-path decision carries an environmental cost. As world leaders and industry stakeholders gather to accelerate climate commitments, digital advertising professionals must play their part by understanding, estimating, and reducing their environmental footprint.
For brands, agencies, publishers, and platforms, this moment highlights an essential point:
Even as the industry’s focus shifts, sustainability remains a key responsibility. And gaining a solid understanding of its role in digital advertising will help professionals contribute meaningfully to a more accountable and resilient ecosystem.
To help the industry meet this demand, we’ve launched a condensed, half-day online course on Environmental Sustainability in Digital Advertising, designed to equip professionals with the knowledge, frameworks, and practical tools they need to take meaningful action.
With 2026 on the horizon, many organisations are assessing how to build the right capabilities for a more responsible and efficient digital world. Sustainability remains an important part of that picture, helping teams make smarter decisions, reduce impact, and meet continually changing expectations.
Yet many still lack confidence in how to:
Strengthening these skills now means entering the new year better equipped to operate responsibly, respond to client needs, and contribute to a more transparent and robust industry. Ultimately, sustainability knowledge is becoming a practical advantage, supporting both performance and accountability.
This half-day online course is designed to give you, or your team, a comprehensive yet practical overview of how sustainability applies to digital advertising.
You will learn how to:
This is not just theory. It’s practical knowledge you can use immediately.
This course is ideal for:
Whether you’re a beginner or looking to formalise your understanding, this training will provide tangible value that helps you speak the language of sustainability and act on it.
Dimitris Beis, Data Analyst & Sustainability Lead at IAB Europe, will lead the sessions. Dimitris works at the intersection of advertising and environmental responsibility, helping the industry understand measurement complexities, activate best practices, and ensure sustainability progress aligns with real-world standards.
His hands-on experience and knowledge of the European digital ecosystem ensure you’ll leave with practical insights, not just theory.
We know that time is precious. That’s why this programme has been designed to deliver maximum value in just half a day.
Choose from:
Both sessions are virtual, enabling you to join live from anywhere.
Don’t forget, if your organisation is part of the IAB Europe network, you can access a discounted rate. Email the team at communication [at] iabeurope.eu for more information.
Head over to our training page for more information on the course and secure your spot today.
In September, we hosted our inaugural Retail Media Impact Summit in the heart of Amsterdam. A landmark event that brought together over 150 industry leaders to share insights, strategies, and bold ideas to help shape the future of Retail Media in Europe. One of the themes of the day was the transformative role of AI in driving smarter campaigns, better measurement, and richer shopper experiences.
To continue the great conversations sparked at the Summit, we caught up with Andreas Preuer, Senior Director, Business Development - EMEA at Moloco, one of our expert speakers, to dive deeper into this exciting topic and explore what lies ahead for Retail Media in the age of AI.
You can watch our highlights reel and catch up on all of the action from the day here, and get Andreas’ thoughts below.
“AI finally lets retailers activate their most valuable asset—first-party data—at scale and in real time. Instead of relying on static rules or third-party identifiers, models can predict intent, optimise bids, and match the right ad to the right shopper across billions of auction decisions.
This transformation helps retailers balance objectives like GMV, margin protection, and shopper experience. It also compresses the feedback loop from weeks to milliseconds, so learning compounds and campaigns continually improve rather than plateau.
The timing matters because retail media has reached an inflection point. Advertisers are demanding proof of incremental performance, not just vanity metrics. Shoppers expect seamless, helpful experiences. And retailers need to monetise without degrading customer satisfaction. AI is the only way to balance all three of these priorities simultaneously.”
“We’re seeing a shift from manual campaign optimisation to outcome-based automation. Advertisers are moving away from constantly tinkering with CPC or CPM bids and instead setting business objectives—target ROAS, cost-per-acquisition, or new-to-brand goals—while AI handles the tactical execution in real time.
This approach delivers dramatic efficiency improvements. Retailers using AI-powered personalisation combined with outcome-based bidding can increase ad load without degrading the consumer experience, which creates substantial value and breaks previous growth ceilings.”
“The best retail media doesn't feel like advertising but helpful discovery. AI makes true ad personalisation possible by understanding shopper intent and matching it with relevant products, even when the shopper doesn't know exactly what they're looking for.
Think about someone searching for "comfortable shoes for standing all day." Traditional keyword matching might show generic athletic shoes, while AI can process that query along with session behaviour and surface curated products like supportive work shoes, gel insoles, or compression socks.
AI also prevents ad fatigue and overexposure by understanding when a shopper has seen enough and adjusting frequency accordingly. When done right, AI-powered ads improve key engagement metrics. We've seen partners achieve 30% higher click-through rates because the recommendations are genuinely relevant, which boosts both ad revenue and overall sales.”
“I'm most excited about the standardisation of AI-native incrementality measurement. For too long, an overemphasis on last-click attribution has made it hard for retailers and marketers to gauge real impact. Now, advertisers are demanding proof that campaigns drive purchases that wouldn't have happened without ads.
At Moloco, we use a ghost bidding methodology that measures incrementality during live campaigns without the revenue sacrifice of traditional holdout groups. Early testing shows that up to 29% of conversions among exposed onsite users were truly incremental—new business that suppliers would have otherwise missed. This type of rigorous testing is becoming table stakes.
I'm also watching agentic AI closely. We'll see AI agents acting as personal shoppers on owned-and-operated properties, helping customers navigate complex catalogues using natural language. For retailers with extensive product ranges, this could dramatically improve discovery and reduce decision fatigue.”
“The Retail Media Impact Summit was one of the best events I’ve attended this year, bringing together heads of Retail Media Networks, leaders representing top brands, and agency executives. My biggest takeaway is that Retail Media continues to be the largest margin driver in retail, and AI will deliver the next wave of growth and scale for retailers, resulting in highly personalised ads, outcomes-based buying, and improved automation.
What also struck me was the shared challenge across the room: leaders are being asked to deliver future growth without additional resources or headcount. This is where AI becomes essential rather than optional. The technology exists today to automate campaign creation, optimise in real time, and dramatically improve efficiency. Retailers who embrace this, focusing on change management alongside technology modernisation, will build a sustainable advantage in the years ahead.”
To hear more from Andreas on how AI is advancing Retail Media, tune into our Retail Media Roundtable podcast episode, recorded live at the Retail Media Impact Summit. In the episode, Andreas joins Drew Cashmore, Managing Director, Adaptive Retail Group & Chief Strategist, Vantage, to discuss how AI is reshaping strategy, measurement and shopper experience in the space.
At our Retail Media Impact Summit in Amsterdam, one of the most thought-provoking sessions tackled a critical and often debated topic in Retail and Commerce Media: incrementality measurement. As Retail media continues to mature, understanding what truly drives incremental outcomes - and how to measure them effectively - has become one of the industry’s most pressing challenges.
During this breakout session, to set the stage, we conducted a live poll among attendees, asking two key questions:
1. Is the industry the gold standard for measurement in Retail Media?
2. Incrementality is a noble goal, but constraints make it nearly impossible to achieve.
Interestingly, 60% of participants agreed with the second statement. This result highlights a shared sentiment across the ecosystem. While incrementality represents an ideal in campaign measurement, it remains complex and, in many cases, difficult to implement in practice.
As discussed during the session, incrementality implies causality, yet causality itself exists in many shades. The reality is that not all incremental measurements are created equal, and this complexity makes standardisation a challenge for the industry.
During the session, our Retail Media Consultant, Yara Daher and IAB US’ VP Commerce & Retail Media, Collin Colburn, presented a preview of the new IAB Europe and IAB U.S. Guidelines for Incrementality Measurement in Commerce Media. Officially launched today, the guidelines offer a comprehensive look at the state of incrementality measurement, providing a framework for navigating the wide range of methodologies available and the conditions under which they perform best.
The Guidelines identify four primary approaches currently used across the industry:
Each approach offers its own advantages and limitations - from precision and scalability to practicality and resource requirements. The goal of this work is to help buyers, sellers, and technology partners align on common principles and expectations when it comes to proving true incremental impact.
Download the Incrementality Guidelines from the IAB Europe website here.
We discussed the four different approaches to incrementality: experiment-based, model-based counterfactual, econometric and hybrid proxies. Although everyone agrees experiment-based marketing holds the most rigour, it is not always possible. We then went on to discuss the growing adoption of Model-Based methods, such as Synthetic Controls and Ghost Ads. These techniques are gaining traction as advertisers and retailers seek more scalable ways to assess campaign performance.
However, as several participants noted, these methods are still in their experimental phase within the European market. Questions remain about their reliability, consistency of inputs, and potential for cross-platform validation. Continued collaboration between data providers, retailers, and technology partners will be key to refining these models and driving wider adoption.
Adding a practical perspective, Stan Lajouanie, VP Brand EU & LATAM from LiveRamp, shared how LiveRamp is enabling retailers and brands to unlock more actionable insights from incrementality measurement. The company is helping push incrementality measurement into social media environments, ensuring retailers can deliver key insights through Conversions APIs (CAPIs) and develop strategies that align more closely across different media channels.
This interoperability is essential for a holistic understanding of performance - particularly as retail media expands into off-site environments and across multiple walled gardens.
As we look ahead, we will continue to explore how incrementality data can be made more accessible and actionable across the wider industry and will examine the merits of each measurement approach. The newly released guidelines provide a strong foundation for this next phase of work.
For more information on our Retail Media work and how you can get involved, visit our Retail Media Hub here, or reach out to our Industry Development & Insights Director, Marie-Clare at puffett [at] iabeurope.eu.
On 21st October, we hosted our first-ever Connected TV (CTV) Workshop in Brussels, bringing together sell-side experts from EGTA, Amazon, ProSiebenSat1, Google YouTube, RMB Belgium, Pubitalia and IAB UK for an engaging afternoon of collaboration, insight sharing, and discussion.
Connected TV (CTV) continues to be one of the fastest-growing areas of digital advertising in Europe. According to our 2024 AdEx Benchmark Report, investment in BVOD and SVOD environments has grown significantly over the past few years, reflecting the increasing convergence of traditional TV and digital channels.
According to our research with DoubleVerify, 50% of European buyers now frequently consider CTV as part of their media mix - a clear signal that this channel is becoming a core component of cross-screen strategies. But, despite this momentum, challenges persist, particularly when it comes to measurement.
The research also shows that while advertisers see huge potential in CTV, many still face a lack of transparency. That’s why IAB Europe continues to support the sustainable growth of this channel by bringing industry experts together to discuss common challenges, identify solutions, and work towards greater clarity, standardisation, and transparency in CTV.
During the session, participants reviewed key buy-side questions around measurement, verification, and delivery, explored existing guidelines such as those from the Media Rating Council (MRC), and discussed what IAB Europe’s CTV Working Group can do to build on these frameworks to strengthen the European market.
Participants highlighted a range of pressing issues that need to be addressed to unlock CTV’s full potential across European markets.
The group discussed the need for a harmonised approach to measurement.
Commonly requested metrics include:
While BVOD-style metrics such as impressions remain dominant, many platforms still reject third-party tracking. Participants agreed that measurement data should integrate with brand and agency models to enable more holistic analysis.
A recurring theme was the lack of shared definitions across European markets. Participants agreed that mapping how inventory is sold and bought should come before standardisation. While frameworks like the IAB Tech Lab’s Content Taxonomy exist, they are not yet widely adopted.
It was suggested to align with MRC definitions and categorise metrics into “must have,” “should have,” and “nice to have” to support future harmonisation efforts.
We have already released the first set of definitions, which can be viewed in our newly published Digital Video Framework and Glossary.
There is a strong need for education across the ecosystem — from understanding CTV formats and buying options to factoring co-viewing into measurement models. Participants also highlighted the importance of achieving regional parity in data and research to support better outcomes.
The group suggested developing a CTV capability map to support market understanding - an initiative that is already in progress within the CTV Working Group.
Building a core set of transparency principles was seen as a key next step to unify the market. Both buy-side and sell-side participants emphasised the need for stronger alignment on targeting and verification approaches.
The group agreed on several follow-up actions to keep the momentum going:
The first CTV Workshop marked an important step forward for our work in this space.
Stay tuned for more updates from our CTV Working Group as we continue to drive progress in this space. And if you’re keen to get involved, reach out to our Industry Development & Insights Director, Marie-Clare, at puffett [at] iabeuorpe.eu for more information.
Brussels, Belgium, 31st October 2025 – IAB Europe, together with Alliance Digitale, BVDW, IAB Italia, IAB Polska, IAB Spain, and SPIR, has submitted a joint response to the European Data Protection Board’s (EDPB) public consultation on its draft Guidelines 3/2025 on the interplay between the Digital Services Act (DSA) and the General Data Protection Regulation (GDPR).
We welcome the opportunity to provide feedback on this important guidance which aims to clarify how two cornerstone pieces of EU legislation - the DSA and the GDPR - interact in practice. However, we are concerned that the draft Guidelines were developed without the involvement of the Digital Services Coordinators (DSCs), the European Board for Digital Services (EBDS), or the European Commission.
We believe that effective and coherent implementation of the DSA and the GDPR requires close coordination between all competent regulators, as the EDPB itself emphasised in its Helsinki Statement. We therefore encourage the EDPB to revise the draft Guidelines to ensure appropriate consultation with relevant regulators, and to refrain from interpreting substantive provisions of the DSA that fall outside its competence.
Key Points of Our Response
1. Automated Decision-Making and Advertising
The draft Guidelines suggest that personalised advertising could, in some cases, fall within the scope of automated decision-making under Article 22(1) GDPR. We ask the EDPB to clarify that advertising – including personalised advertising – does not, in itself, constitute automated decision-making producing legal or similarly significant effects on users. Advertising is fundamentally distinct from decisions such as credit scoring or employment selection and should not be treated as such under the GDPR.
2. Legal Grounds and Security Obligations for Article 26 DSA
Article 26(1) of the DSA requires online platforms to provide meaningful information about advertisement targeting and funding, creating obligations that may involve processing personal data. While the DSA imposes direct obligations only on platforms, third-party companies that support ad placement may also process data to enable compliance. The draft Guidelines should clarify that such processing can rely on the legal obligation basis or, alternatively, on the legitimate interests basis, given the clear regulatory purpose and straightforward necessity and balancing tests. Although technical and organisational safeguards must be applied to such processing, the EDPB should recognise that access to personal data by third parties is not prohibited if it is limited to compliance purposes, respecting the GDPR principles of purpose limitation, data minimisation, and security.
3. Scope of Special Categories of Data
Although recent CJEU rulings have broadened the interpretation of “special categories data” under Article 9 GDPR, we caution against an overly expansive approach that could create unnecessary complexity for legitimate processing activities, such as brand safety. We recommend that the EDPB clarify that intent and actual inference must both be present for processing to fall within Article 9’s scope.
4. Proportionality in Age Verification
We call on the EDPB to adopt a risk-based and proportionate approach to age assurance, consistent with the GDPR and the Commission’s Article 28 DSA Guidelines. A flexible approach is essential to allow platforms to implement effective and context-appropriate measures for protecting minors online.
5. Cooperation Between Regulators
Finally, we emphasise the need for structured cooperation between Data Protection Authorities (DPAs), Digital Services Coordinators (DSCs), the European Board for Digital Services (EBDS), and the European Commission. The draft Guidelines should refrain from interpreting substantive DSA provisions beyond the EDPB’s remit and focus instead on clarifying GDPR obligations where personal data processing is concerned. Enhanced coordination is essential to avoid duplicative proceedings and ensure consistent enforcement.
The response to the public consultation can be found here. For more information, please contact Ninon Vagner - vagner [at] iabeurope.eu / Lauren Wakefield - wakefield [at] iabeurope.eu
Brussels, 27th October 2025 – On 23rd October, IAB Europe submitted its response to the European Commission’s public consultation on the Digital Fairness Act (DFA), which will contribute to the Commission’s impact assessment and inform a future legislative proposal.
In its submission, IAB Europe focused on key areas relevant to the digital advertising industry, including dark patterns, unfair personalisation and the use of personal data, influencer marketing, horizontal issues, and regulatory simplification.
Before addressing these areas, IAB Europe noted potential shortcomings in the consultation’s design that could distort the evidence base and result in biased outcomes in favour of EU action. It urged the Commission to account for these biases in the final report through contextual analysis, comparison with other data sources, and transparent communication of uncertainties.
IAB Europe reiterated its long-standing position - most recently communicated in a joint industry letter to Executive Vice President Virkkunen and Commissioner McGrath in July 2025 - that rather than introducing new rules affecting the digital advertising industry, the EU should prioritise the full and consistent implementation of the existing rules across Member States. The effectiveness of this framework should also be properly assessed, including recently introduced regulations not fully covered in the Fitness Check, such as the Digital Services Act (DSA).
You can access IAB Europe’s full response to the Digital Fairness Act consultation here, and the supporting position paper here.
For further information, please contact Ines Talavera, Public Policy Manager, IAB Europe - talavera [at] iabeurope.eu, or Lauren Wakefield, IAB Europe - wakefield [at] iabeurope.eu.
